Justification

memo

Federal Bureau of Investigation (FBI) Criminal Justice Information Services (CJIS) Division
To:	Office of Management and Budget
From:	FBI’s CJIS Division
CC:	Melody Braswell; Robin A. Stark-Nutter
Date:	November 13, 2018
Re:	Revisions to Collection Instrument Created in Support of the Fix NICS Act of 2018
Comments:	The purpose of this communication is to provide a justification for the substantive changes made to the Fix NICS Act State Implementation Plan Survey, as published in the federal register on October 24, 2018. A working group was established to collaborate on the creation of a collection tool that would serve to fulfill the requirement for the Attorney General to work with each state to establish an Implementation Plan that would ensure the reporting of appropriate records to the NICS. Due to a miscommunication, a draft of the template was provided to the OMB and consequently published in the federal register. While the bulk of the template survey remains the same (with some minor editing), there is one substantial change. There are seven federal firearm categories where it is believed state agencies may create or possess records. The same set of questions were posed within those seven categories. It was determined that one question out of that set could be removed. This question asked agencies to quantify the amount of records they may have relevant to each of the seven prohibitions and due to the time sensitive nature and at times, temporary validity of some records, it was subsequently determined there would be no value in asking respondents to respond to that question.